I strongly object to…

I strongly object to exempting “all permits and orders issued under the Species Conservation Act from the requirements of Part II of the Environmental Bill of Rights.” It seems that permits and orders issued under the SCA would be “exempt from the public participation requirements of Part II of the Environmental Bill of Rights, such as the right for the public to be notified, comment, and provide input before decisions are made.” If I understand well, the government is looking to AVOID/MINIMIZE PUBLIC CONSULTATIONS on environmentally significant policies, acts and regulations. This seems to be a step backwards for citizens’ democratic participation in society; but a relief for government to not have bother with the inconvenience of listening to citizens to whom you are responsible and accountable. It is a good strategy for fast-tracking development / resource extraction / economic projects, no matter the consequences on the animals and vegetation of Ontario, their habitat, but also habitats that provide “ecosystem services” to humans (such as flood mitigation, carbon sink, fresh air, and interconnected relationships/benefits that we have yet to understand, etc). If passed, citizens Will Not Know that anything is happening to our environment until the damage is done and it’s too late.

It is good to “prescribe the SCA as being subject to Part IV (Application for Review), Part V (Application for Investigation) and Part VII (Employee Reprisals) of the Environmental Bill of Rights.” But that really leaves the onus on citizens to actively search to find out what the government is doing. How can we do that if decisions are being made by Cabinet or particular ministers who are no longer obliged to be transparent about their decisions? So even though this is a good prescription, it seems toothless, weak and irrelevant. It needs to be paired with KEEPING Part II of the Environmental Bill of Rights. For example, the Environmental Registry of Ontario (ERO) is a great tool for citizen engagement and input. (Although it is likely a red tape roadblock for government that wants to move forward with projects by “trusted proponents”.)

Regarding updating the Species at Risk list to the Proposed Protects Species List: I object to letting “species of concern” disappear from our radar and not be included on the list. I object to leaving protections for migratory birds and fish solely in the care of the federal Species at Risk Act. With the passed Bill C-5, we see that the Federal Government is taking the same tack as Ontario’s government, assuming the power to waive environmental assessments and protections for the benefit of “trusted proponents” spearheading major projects: meaning that these animals under the SARA could very well be left completely without protection.

I think it is strange that in SCA Section 13 (1), COSSARO “shall not submit an additional report with respect to the classification of species to the Minister” unless the Minister wants the report or a report would be about a species that is not listed in their annual report. What if, in the course of a year, it becomes clear that a species has swiftly changed classification? Or what if there was a major oversight/typo in the report that needs correction?

It has been frustrating to read the Proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025 as the actual regulations are not printed there; only summaries are provided; nor am I successful in locating them on the internet.

Number 2: Proposed Registration Regulation. This section uses the word “may” numerous times, which does not communicate a firm commitment to any of what is proposed for the regulation. How do we know what are the criteria for “the activity is excepted from the SCA”? How can citizens provide informed and adequate input?

“Information submitted to the Registry may be made publicly available to support transparency.” I strongly think that it should say “shall be made publicly available”, considering that the SCA will exempt requirements under Part II of the Environmental Bill of Rights.

The phrase, “Registrants may be required to work with qualified professionals to develop site-specific conservation plans that include actions to avoid or reduce impacts on species and their habitats” needs to say “SHALL be required to work with qualified professionals”. Otherwise, how will a registrant (trusted proponent) know what to include as “responsible planning” or what conservation outcomes to support? How will they know that their activity “adversely impacts a protected species” or a species’ habitat? How will they know what actions to take to avoid impacts, minimize adverse impacts, mitigate lasting impacts? How will they know what to put into a conservation plan or what to monitor or report? It would read and be better implemented as: “Registrants SHALL work with qualified professionals to develop site-specific conservation plans that include actions to avoid or reduce impacts on species and their habitats”. The qualified professionals should be independent, objective; and not feel pressured to give watered down advice in order to keep their employment secure.

Why are we obliged to participate in the dichotomy of EITHER environmental stewardship OR economic/business/provincial/human prosperity? As a citizen of Ontario, I would like our province to be known as the example for how to develop economic prosperity AND prioritize sincere ecological stewardship.